California, United States of America
The following excerpt is from People v. Brown, 14 Cal.App.5th 320, 221 Cal.Rptr.3d 854 (Cal. App. 2017):
Crawford v. Washington (2004) 541 U.S. 36, 56, 124 S.Ct. 1354, 1367, 158 L.Ed.2d 177, 195-196 ["Most of the hearsay exceptions covered statements that by their nature were not testimonialfor example, business records or statements in furtherance of a conspiracy "], italics added.)
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